Criminal Law Library Blog
January 11, 2010 No. 08-809.
The defendant, Troy Brown, had alleged on appeal that the state mischaracterized the probability that his DNA matched that of someone in the general population. He also claimed that a prosecution expert had misstated the chances of a DNA match between himself and his two brothers. All three lived near the victim.
“DNA evidence remains powerful inculpatory evidence even though the state concedes [its expert] overstated its probative value,” the Supreme Court wrote in McDaniel v. Brown.
The court remanded for consideration of Brown’s claims of ineffective assistance.
From: Per Curiam:
” In Jackson v. Virginia, 443 U. S. 307 (1979), we held that a state prisoner is entitled to habeas corpus relief if afederal judge finds that “upon the record evidence adducedat the trial no rational trier of fact could have found proofof guilt beyond a reasonable doubt.” Id., at 324. A Nevada jury convicted respondent of rape; the evidence presented included DNA evidence matching respondent’s DNA pro-file. Nevertheless, relying upon a report prepared by aDNA expert over 11 years after the trial, the Federal District Court applied the Jackson standard and grantedthe writ. A divided Court of Appeals affirmed. Brown v. Farwell, 525 F. 3d 787 (CA9 2008). We granted certiorarito consider whether those courts misapplied Jackson. Because the trial record includes both the DNA evidence and other convincing evidence of guilt, we conclude that they clearly did”.